Accurate business records are essential to the management of the Company. All of Ferring’s books, records, and accounts must fully and accurately reflect the Company’s business transactions. These include time sheets, vouchers, bills, invoices, expense reports, payroll and benefits records, performance evaluations, and other essential Company data.
It is your responsibility to report any unrecorded funds or assets or false or artificial entries in the books and records of the Company if you become aware of them. If you learn of or suspect accounting fraud, report it immediately by contacting the Corporate Compliance Office or Corporate Internal Audit.
Preserving the privacy of personal information is critically important. Every employee, as well as job applicants, research study subjects, research investigators, patients, healthcare professionals, vendors, suppliers and many other people around the world, provide personal information to Ferring.
Sharing personal information with Ferring is an act of trust. Keeping that information confidential and secure is often a legal requirement and always a demonstration of our commitment to Ferring’s values of integrity and respect for people.
All Ferring employees and contractors are accountable for protecting personal information and for processing such information only within the boundaries of applicable law and Ferring procedures. Help protect the privacy of personal information by following these principles:
- Collect personal information only for legitimate business purposes and keep it only as long as necessary to fulfill those purposes and meet our legal obligations.
- Take adequate precautions to safeguard personal information when collecting, processing, storing, and transferring information.
- Only share personal information with individuals who have a legitimate need for it and will protect it properly.
- When appropriate and in accordance with local laws, give notice and/or obtain consent when collecting, processing, transferring, and storing an individual’s personal information.
- Allow employees whose personal data is held by the Company to review and correct such information.
- Properly destroy records containing personal information according to Company guidelines.
Ferring’s reputation and the trust and confidence of those with whom we do business are among our most vital corporate resources. Our company is committed to conducting its affairs in a uniformly ethical manner and pursuant to a standard of fundamental honesty and fair dealing. This standard requires adherence to all laws, regulations, and normal ethical practices that apply to the company’s business activities. Ferring adheres to the PhRMA Code when interacting with its customers and how it approaches its business. A copy of the PhRMA Code can be found on Ferring’s external website www.ferringusa.com by pulling down the “About Ferring” tab and then the “Compliance Policies & Procedures” tab.
Areas of Potential Conflict:
Employees have a responsibility to work in the best interests of the company and to avoid situations and actions that may be or create the appearance of being in conflict with the company’s objectives and principles. While it is not possible to list every circumstance that may lead to a conflict of interest, the following are examples of employee activities that must be avoided:
- Holding a substantial financial interest in any enterprise with which the company has business dealings (e.g., competitors, suppliers, and customers). (Interest of less than $5,000 or that regardless of value, amount to less than one percent of an enterprise are not considered to be substantial);
- Accepting, directly or indirectly, from any vendor or supplier of services, any vacations, cash payment ($100 or more; other than reimbursement of reasonable out-of-pocket expenses), service, loan (except from banks or other financial institutions), or discount (except those offered to employees of the Company) by an employee or any member of an employee’s immediate family;
- Accepting gifts or other benefits of greater than nominal value per year (i.e. $200) from any vendor or supplier of materials or services.
In addition to these prohibitions, there are borderline situations that give rise to possible conflicts of interest. The following serves as a guide to the types of activities that should be fully reported to the company:
- Acting as a director, officer, or employee (present or within the past five years) of any business or other institution with which the Company has a competitive or significant business relationship. The employee should report to his or her supervisor any situation in which members of the employee’s immediate household hold positions that are likely to cause the employee to have a conflict between the interests of the Company and another institution;
- Employment of a relative or member of management by a company doing business or seeking to do business with our Company;
- Competing with the Company for the purchase or sale of any kind of property (tangible or intangible) or diverting a business opportunity from the Company for the employee’s personal interest;
- Using Company assets (e.g., funds, facilities, know-how, or personnel) for the benefit of other business or personal interests;
- Engaging in outside activities that reduce the employee’s impartiality or judgment or that may interfere with or adversely affect the employee’s ability to perform company work.
From time to time, employees may be asked to represent the company before an outside group or trade association. In such instances, employees may accept expense reimbursement but should decline any fees offered. If an honorarium cannot be declined, the employee should request that the granting organization contribute the honorarium to a charity or some other nonprofit agency. Please refer to IRS code Section 501(C)(3) Organizations.
Approvals and Advice:
Employees are encouraged to discuss issues and concerns pertaining to the Company’s commitment to ethical business practices with their supervisors. This policy is supplementary to the Ferring Corporate Policy. All managers shall be responsible for the enforcement of compliance with this policy. Employees must obtain approval from their supervisor, the appropriate area or functional vice president, and the Human Resources Department before undertaking any of the activities identified as possible conflicts of interest in this business ethics policy.
Compliance with this policy of business ethics and conduct is the responsibility of every Ferring employee. Disregarding or failing to comply with this standard of business ethics and conduct could lead to disciplinary action, up to and including possible termination of employment.